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IBLA 85-723 •~ Both the Calvert and Marsh and Bannock decisions are instructive An determiniry whether the State took appropriate action following OSMRE's l0~ay notice. In Calvert and Marsh, the State of Alabama, upon receiving OSMRE's 10-day notice, took no enforoanent action that would cause the viola- tion to be corrected. 95 IBLA at 189. In Bannock, the State of Ohio revoked its approval of a bond release affecting prime farmland, but upon a subsequent reversal of this action took ro affirnetive steps to correct the violation for which 09RiE gave it notice. In each wse, the Board found that the State had failed to take appropriate action to correct the violatior~ charged. A similar conclusion was reached in TLrner Brothers, Inc. v. Offir:e of Surface Mining Reclamation and Enfoccerrent, 92 IBLA 320 (1986). In that: case, the State of Oklatroma did, in fact, issue an NOV in response to O6MRE's LO~ay notice. The Board found this action by the State to be not 'appropriate action,' however, because the State had issued an NOV for the same violation over a year earlier. Mere issuance of a second State NOV did not amount to 'appropriate action' as would ereure abatement of the violation, the Board concluded. See also Peabody Coal Co. v. Office of Surface Mining Reclama- tion and E7rforcenent, 95 IBLA 204, 94 I.D. 12 (1987). [2) Rey to each of these decisions is a determination whether the State took such action as would cause the violation to be corrected. No definition of the phrase •appropriate action" has been spelled out by OSMRE because, as explained in the preamble to 30 CFR 843.12, •[tlhe crucial response of a State is to take whatever enforcement action is necessary to secure abatement of the violation." 47 FR 35627-28 (Aug. 16, 1982). Alabama's response, as noted above, was to decline to act because, in its view, release of appellant's bond precluded further jurisdiction. This inaction did nothing to correct the vegetation violation identified by 0.5MRE. Nor did the State demoretrate good cause in declining to act to correct this violation. Implicit in its bond release was a finding by the State that appellant satisfied relevant revegetation standards. Thus, the State's response to the 10-day notice amounted to a denial that a violation, in fact, existed. Lacking as it was in facts that might persuade OSMRE otherwise, OSMRE could properly rnnclude that the State's response failed to demoretrate good cause for State inaction. Our review of the case law discussed above indicates that OSMRE properly determined that Alabama failed to take appro- priate action to wrrect the violation, or show good cause for its failure to do so, as is required by section 521(a)(1) of the Act. Appellant's con- trary contentions aze rejected. Appellant's final argument challenges the validity of the 'point fre- quency' method used by OSMRE to determine whether appellant satisfied the appropriate vegetation standard. 'fiat standard is set forth at regulation No. 3, sec. 3(C) and (D), of the Alabama Surface Mining Reclamation Commission (ASMRC), which states: C. Permanent vegetation shall be deemed adequate vegeta- tive cover if the vegetation has survived two growing seasons, and if the following standards are observed: 100 IBLA 303